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IN THE COURT OF COMMON PLEAS
CUYAHOGA COUNTY, OHIO

NICHOLAS J. AVRAMAUTv
Administrator# etc., et al.
Plaintiffsp
Vs* CASE NO. 112695
RICHARD ESSIGr M.D.r
et al.r
Defendants.


Deposition of JUSTIN P. LAVIN, JR.# M.D.r a
Witness hereint called by the Plaintiffs for
cross-examination pursuant to the Rules of Civil
Procedurep taken before me, the undersigned, William S.
Bish, an RPR/CM and Notary Public in and for the State of
Ohiop at the office of Justin P. Lavint Jr., M.D., 525
East Market Street, Akron, Ohio, on Tuesdayp the 5tb day
of September, 1989, at 8:00 o'clock p.m.



COMPUTERIZED TRANSCRIPTION BY
BISH & ASSOCIATESr INC.
524 Society Building
Akron, Ohio 44308
(216) 762-0031


A"

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2


APPEARANCESs

On Behalf of the Plaintiffst

Messrs.  Jerome M. Ellerin Co.# L.P.A.

Byz Jerome M. Ellerin# Attorney at Law
and
Leslie W. Chavers, Attorney at Law
The Bond Court Building
Clevelandf Ohio 44114

On Behalf of the Defendant Richard Essig# M.D*:

Messrs.  Quandtr Giffels# Buck & Rodgers
Co,, L.P.A.

By: Beth A. Sebaugh, Attorney at Law
800 Leader Building
Clevelandp Ohio 44114

On Behalf of the Defendants Nauricio Camacho#,
M.D. and Samuel J. Joy, M.D.:

Messrs.  Reminger & Reminger Co,# L.P*A.

By: John R. Irwin, M.D.p Attorney at Law
The 113 Building
113 St. Clair Avenue# N.E.
Cleveland, Ohio 44114-1273

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3
S T I P U L A T I 0 N S
It is stipulated by and between counsel for the
respective parties that the deposition of JUSTIN P.
LAVINF JR.# M.D.F a Witness hereing called by the
Plaintiffs for cross-examination pursuant to the Rules of
Civil Procedureo, may be taken at this time by agreement
of counsel and without notice or other legal formality;
that proof of the official character of the Notary is
waived; that said deposition may be taken in Stenotype by
the Notary, whose notes may thereafter be transcribed by
or for the Notary out of the presence of the witness*
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4




1 N D E X

Exhibit No. Marked

Plaintiff's No. 19
Plaintiff's Nos. 2
through 4 11



Examination by: Page

Mr. Ellerin  5
 65

Mr. Irwin  56
 66

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 5

1 JUSTIN P. LAVINr JR.j M.D.
2 of lawful ager a Witness hereinp having been first duly
3 sworn, as hereinafter certified, deposed and said as
4 follows:
5 MR. ELLERIN: Let the record show that
6 this is the discovery deposition of Dr. Lavin in the
7 Avramaut case with al